IPC in an AATD

In short, the ACS has an appendix that states that an IPC may be performed on an AATD if the Letter of Authorization states that is can...except that a circle to land must be done in an aircraft itself.

61.57 (d) seems to exclude an aviation training device as one of the options I which an IPC may be accomplished.

Am I missing something, or is it confusing to others? I was unsure back when it was the PTS but always defaulted to just using an airplane.

3 Answers

Mark Kolber on Aug 26, 2016

This one ain’t easy to follow, but I think for a good reason. For years, a big complaint against the FAA was (and continues to be) that, as a government bureaucracy, it is inherently slow. Amending the FAR is a process that requires notice, comment, revision, sometimes with multiple iterations of each. Compare that to the rapid growth of technology in things like GPS and flight simulation devices.

So, the FAA began to loosen up a little. Most of the operational rules of what qualifies for different GPS functions are found, not in the FAR, but in “guidance material” with the basic FAR being the definition of “suitable RNAV system” in FAR 1.1 which includes “information on suitable RNAV systems is published in FAA guidance material.”)

Same for the operational permissions for flight simulation devices. That one is in 61.4 which ends with “The Administrator may approve a device other than a flight simulator or flight training device for specific purposes.” IOW, if the Administrator issues a certification to a device that says, “use it for an IPA,” you can use it for an IPC.

So, practically speaking, you are back to looking at something simple – what does the certification letter for the specific device say it is approved for?

I pulled up the LOA for the Redbird. It allows for an IPC to be conducted.

I would bet my bottom dollar that the FAA generated one approval letter for an AATD and used that as a template to create all the other approval letters. Following this line of reasoning, I would assume that pretty much any AATD will be approved for an IPC.

However, your caution to check the approval letter for the individual device is the best idea.

Also, make sure the letter is the most recent one. They began reissuing LOAs in the fall of 2014. If the letter is a current version, it will contain an expiration date for 60 months after the date it was written.

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